BIR Ruling No. 490-2017

BUREAU OF INTERNAL REVENUE REP(BLIC OF THF PHLIPPINES DHPARTMENT OF FINANCE Quczon City

Certificate of Tax Exemption No: 490-2

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Identification Number withholding tax on its income received directly in connection with its economic and low-cost housing project (horizontal). Tektone Village. consisting of 144 units located at Brgy. Lapu- in no case earlicr than the date of registration of the project with the BOI. pursuant to Executive Order No. 226. otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98. as amended. Lapu. Lcgazpi City. a project duly registered with thc Board of Investments (BOI) under Registration No. from October 2015 or actual start of commercial operations/selling, whichever is earlier. but This certifies thal EMBARCADERO LAND VENTURES, INC.. with Tax dated October 26, 2015. for a period of four (4) years beginning is exempt from income tax and crediiable

bclow, or house and lot and other residentiai dwellings valued at P3.199.200.00 and below, is VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended. Moreover. the sale by the Company of residential lots valued at P1.919.500.00 and

be subject to the regular taxes that may be applicabte. The sale. however. of housing units in excess of the 1 44 units registered with BOI shall

applicable BIR rules and reguiations and the Terms and Conditions stated at the back hereof. The Company is liable, however. for all other applicable taxes not discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of

documents as represented and submitted. However, if upon investigation. the BIR ascertains that the facts are different. then this Certificate shall be considered null and void. issued thisday of _0CL1917 This Certificatc of Tax Exemption is being issued on the basis of the facts and

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K - Commissioner of Internal Revenue CAESAR R. DULAY 010043

Embarcadero I.and Ventures. Ine. Page 2 ot 2 Date issued Cte No. L 01 c?

OF THE CERTIFICATE OF TAX EXEMPTION TERMS ANI) CONDITIONS

t The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Tektone Village. consisting of 144 units located at Brgy. Lapu-Lapu. Legazpi City. Such exemption shall not cover revenues from units with selling price exceeding P3.000.000.00. 2. The Company is obligated to construct and sell 144 housing units based on the following schedules/sales revenues:

Total Year 4 2 3 (No. of Units) Volumc 14 T 68 0 Value (Php 000)

3. In the computation of the project's ITH. interest income from in-house financing shall not be considered as part of the revenues generated from the registered housing project. 4. The Company's entitlement to ITH for its BOI-registered housing project is subject to the compliance with the provisions of the Specific Terms and Conditions of its BOI Registration.

S Pursuant to Section 4 of Republic Act (RA) No. 10708-. the Company is required to file its tax provided under E.O. 226. within the periods prescribed under R.A. 10708's implementing Rules and Regulations and Joint Mernorandum Circular No. 1 -2016 dated September 1. 2016. returns and pay its tax liabilities, on or before the deadline as provided under the 1997 'Tax Code. as amended. using the electronic system for filing and payment of taxes of the BiR. It shalt file with BOI a complete annual tax incentives report of its income-bascd tax incentives. VAT and duty exemptions, deductions. credits or exclusions from the tax base. as may be

6. 'The Company shall be constituted as a withhoiding agent for the government if it acts as empioyer and any of its employees received compensation income subject to compensation withholding tax. or if it makes payments to individuals or corporations subject to the withholding taxes as source as required under Chapter XIII and Section 57 of the Tax Code of 1997. as ainended and implemented by Revenue Regulations (RR) No. 2-98, as amended.

The Company is required to file on or before the 15th day of the fourth month following the closc of its accounting period of a Profit and Loss Statement and Balance Shcet with the Annual Information Return under oath. stating its gross income and expenses incurred during the taxable year.

8 Finatly. the Company's books of accounts and other pertinent records shall be subject to of 1997. as amended. periodic examination by revenue enforcement officers of this Bureau for the purpose of exemption or lax incentives and its tax liahility. if any. pursuant to Section 235 of the Tax Code c rtaining'whether it is coinplying with the conditions under which it has been granted tax

Investment Promotion Agencies. : An Act Enhancing Transparency in the Management and Accounting of T'ax incentiv es Administered hy